2
respondent's Motion for Entry of Decision. By notice of
deficiency dated August 8, 1989, respondent determined
deficiencies in Federal income taxes, additions to tax, and
additional interest as to petitioner and her former husband Keith
A. Zavitz as follows:
Additions to Tax Additional Interest
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 6659 6621(c)
1979 $878 $44 n/a n/a -0- n/a
1980 2,919 146 n/a n/a $846 2
1981 1,392 n/a $70 1 418 2
1 50 percent of the interest due on the deficiency.
2 120 percent of the interest accruing after Dec. 31, 1984, under sec.
6601 with respect to any substantial underpayment attributable to tax-
motivated transactions.
The underlying issue in this case arose from investment tax
credit carrybacks claimed by petitioner and Mr. Zavitz related to
their investment in the CPG Record Partnership. CPG Record
Partnership leased a master recording from Encore Leasing Corp.
Respondent mailed a notice of deficiency to them on August 8,
1989. Petitioner and Mr. Zavitz mailed a petition for
redetermination on November 6, 1989, which was filed with the Tax
Court on November 13, 1989, to begin a case at docket No. 27416-
89. At the time their petition was filed, they resided in
California. By Order dated July 29, 1997, the Court severed
petitioner from that case for purposes of considering
respondent’s motion for entry of decision.
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